Time & Effort Reporting Guidelines

TIME AND EFFORT REPORTING GUIDELINES

JUNE 2019

Washington State Board for Community and Technical Colleges PO Box 42495

Olympia, WA 98504 SBCTC.edu

Table of Contents

Table of Contents......................................................................................................................................................2 Background ............................................................................................................................................................... 3

What Is Time and Effort Reporting?.....................................................................................................................3 Who Must Complete Time and Effort Reports? ..................................................................................................3 What is Considered a Work-Related Activity? .....................................................................................................4 What Is Contributed or Cost-Shared Effort? ........................................................................................................4 What Is the Difference between Effort Reporting and Payroll Distribution? .....................................................4 Federal Requirements..........................................................................................................................................5 Reasonable Estimates..........................................................................................................................................5 Employee Classifications......................................................................................................................................5 Acceptable Time and Effort Reporting Systems......................................................................................................5 After-the-Fact Activity Report System ..................................................................................................................7 Plan Confirmation System....................................................................................................................................9 Multiple Plan-Confirmation System .................................................................................................................. 12 Incidental Work .................................................................................................................................................. 13 Annual Evaluations ............................................................................................................................................ 13 Additional Information ....................................................................................................................................... 13 Appendix A: After-the-Fact Reporting Checklist.................................................................................................... 14 Report Form ....................................................................................................................................................... 14 Process............................................................................................................................................................... 14 Appendix B: Plan Confirmation Reporting Checklist ............................................................................................ 15 Report Form ....................................................................................................................................................... 15 Process............................................................................................................................................................... 15 Appendix C: Frequently Asked Questions ............................................................................................................. 16

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Washington State Board for Community and Technical Colleges TIME AND EFFORT REPORTING GUIDELINES // June 2019

Background

This guide provides an overview of time and effort reporting as required of educational institutions that receive federally funded grants or SBCTC grants that require time and effort reporting. It includes the minimum requirements for maintaining time and effort reports and reasons why it is necessary.

What Is Time and Effort Reporting?

Time and effort reports are after-the-fact records that reflect how faculty and staff spent the time for which they were compensated by the educational institution. Others terms used to identify time and effort reports include personnel activity reports (PAR) and effort certifications (EC). These terms often are used interchangeably but are not necessarily synonymous.

The purpose of federally mandated time and effort reporting is to provide documentation to substantiate payroll charges. For example, if 25% of an individual's time was charged to a federal grant, time and effort reports must substantiate that the individual spent at least 25% of their time working on activities to support that federal grant.

Time and effort reports must be a single, certified document that reflect 100% of an employee's time worked in a given period.

Proper time and effort reporting includes accounting for salary, wages and benefits and certifying actual time charges for:

1. Each federal grant program.

2. Cost-sharing, matching funds, or leveraged funds required for federal grants.

3. All other activity not funded by a grant (grant and non-grant time) for which the individual staff are compensated.

Who Must Complete Time and Effort Reports?

The federal government requires time and effort reports for all faculty or staff who are compensated, in whole or in part, by a federal grant, or whose efforts are used to satisfy a required or voluntary match or leveraged funds for federal grants.

? Example 1: An adjunct instructor teaches a basic skills class two days a week at a community college funded by the federal Basic Education for Adults (BEDA) Master grant. The individual does not perform any other duties for the college. This individual must maintain a time and effort report because this individual's salary is funded by a federal grant.

? Example 2: A full-time professional-technical instructor teaches welding classes at a community college funded by state funds. The individual receives one-third release-time to coordinate and conduct a non-traditional event funded by the federal Perkins Non-Traditional Employment and Training grant. This individual must maintain a time and effort report because this individual's salary is funded in part by a federal grant.

? Example 3: An individual agrees to teach an `Intro to Computer Skills' class for the state-funded Jobs Skills Program as well as an advanced computer science class for students planning to transfer to a four-year university. This individual does not have to maintain a time and effort report because the salary is not funded at all by a federal grant.

? Example 4: The Basic Education for Adults (BEDA) director of small community college is responsible for teaching a basic skills class for BEDA students (budgeted to the instructional line of the federal BEDA Master grant) as well as maintaining the budgets for the BEDA program (budgeted to the administration line of the federal BEDA Master grant). The remainder of the BEDA director's time is

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Washington State Board for Community and Technical Colleges TIME AND EFFORT REPORTING GUIDELINES // June 2019

charged to state funding used as match for the federal ABE Master grant. This individual must maintain a time and effort report because the individual is funded in part by a federal grant. The time and effort report must separate the time charged to the BEDA Master grant from the time charged to the state funding used as match. However, the time and effort report does not have to split the time applied to the BEDA Master grant between the two budget categories (instructional and administration).

? Example 5: A college Worker Retraining (WRT) specialist serves WRT students. Approximately half of those students are co-enrolled in WRT and Basic Food, Employment and Training (BFET). The specialist's position if funded 100% from state WRT funds. However, 50% of the funds are used as leveraged funds for BFET. This individual must maintain a time and effort report because the individual is partially funded by funds used as leveraged funds for a federal grant. The individual must have two lines on their time and effort report: one line for WRT/BFET leveraged funds (which must identify the original funding source of "WRT" and identify that it is being used as leveraged funds for BFET) and a separate line for the WRT funding that isn't used as leveraged funds for BFET.

What is Considered a Work-Related Activity?

Activities an employee is obligated to provide, whether paid or unpaid, are always considered work-related activity for effort reporting purposes. Activities an employee is not obligated to provide and for which they are not paid, are not considered work-related activity for effort reporting purposes and should not be reported on the PAR.

? Example 1: A full-time basic education for adults (BEDA) faculty is assigned to teach three fivecredit classes and is compensated based upon a full teaching load. However, the agreement with the institution requires the faculty to regularly attend the BEDA professional development trainings without additional compensation. Attending the required trainings is considered workrelated activity and should be included on the PAR.

? Example 2: A full-time career services director is paid as an exempt staff member. Two evenings a week the director voluntarily helps in the writing center assisting professional-technical students write resumes. Even though this activity is related to the director's full-time duties, but since they are not obligated to provide these services, it would not be included on the PAR.

What Is Contributed or Cost-Shared Effort?

Cost sharing represents that portion of the total project costs of a grant agreement that are not borne by the federal government. The educational institution or other non-federal third party pays these costs. Cost-sharing is frequently referred to as matching.

The grantor may require cost sharing (matching), or the institution may volunteer. Regardless, any commitment of effort or matching referenced in the project proposal or the award document must be honored, reported and captured in the time and effort reporting system.

What Is the Difference between Effort Reporting and Payroll Distribution?

Payroll distributions and effort reports are not the same. Payroll distributions are the distribution of an individual's salary and benefits in the accounting records, while effort reports (PARs) describe the allocation of an individual's actual time and effort for specific projects, whether or not reimbursed by the grantor. Payroll distributions to each grant or cost objective are done initially based on budget estimates and then adjusted to agree with effort reports for the final payroll distribution.

? Accounting tracks the detailed payroll accounting transactions to accounts created for individual grant agreements and other institutional activities.

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Washington State Board for Community and Technical Colleges TIME AND EFFORT REPORTING GUIDELINES // June 2019

? Certifying is attesting that salaries, wages and benefits charged to the grants (including required match portions) and to other institutional activities (including voluntary match) is reasonable in relation to the time and effort actually performed. Time and effort reports must be signed by someone with first-hand knowledge of the work performed.

Federal Requirements

2 CFR 200 "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards is the federal government's cost principles for colleges and universities. It defines what costs are allowable and allocable to Federal grants and other assistance programs. Salary, wage and benefit charges to grant awards are allowable only if they are supported and documented by an acceptable time and effort report.

2 CFR 200.430-431, sets the criteria for acceptable methods of charging salary, wages and benefits to federal grants. It requires a payroll distribution system that allocates salary, wages and benefits to the appropriate project accounts based upon reliable personnel activity reports. It also requires the institution to develop procedures to confirm how an individual's time should be charged to each grant award.

Reasonable Estimates

2 CFR 200.430(8)(i)(viii) states: "...Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that...."

2 CFR200.430(8)(i)(viii)(B) goes on to state: "Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. Short term (such as one or two months) fluctuation between workload categories need not be considered as long as the distribution of salaries and wages is reasonable over the longer term."

Employee Classifications

There are two major employee classifications identified by federal regulations:

1. Classified ? Includes part-time and full-time temporary or permanent staff who are overtime eligible or are compensated at an hourly rate, including student workers and workstudy students)

2. Professional/Professorial

A. Professional ? Includes part-time and full-time temporary or permanent exempt and classified staff who are not eligible for overtime

B. Professorial ? Includes tenured, non-tenured, part-time and full-time faculty

Acceptable Time and Effort Reporting Systems

An acceptable effort reporting system must provide records on how individuals participating in federally funded grant programs actually spend their time. Because the federal government mandates effort reporting it is incumbent upon institutions receiving federal funding to maintain accurate and auditable systems and records.

Three examples of acceptable effort reporting systems are:

1. After-the-Fact Activity Report System

2. Plan-Confirmation System

3. Multiple Confirmation System

The After-the-Fact Activity Report System may be used by professional and professorial employees but must be used by classified employees. Only professional and professorial employees may use the Plan-Confirmation

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